Written By krishna on Wednesday, April 06, 2011 | 4:39 AM

This with reference to my letter dated Jun 6, 2007, July 20, 2010 and April 5, 2011 to your Ministry, I wish to submit the facts about the bitter resistance against the proposed waste to energy incinerators in Delhi which is under construction. The Timarpur-Okhla Waste to Energy project based on incineration of Refuse Derived Fuel (RDF).

I wish to draw your attention towards the order of Supreme Court dated 15/5/2007. The case dealt with your ministry's role in municipal waste to energy projects and its failures. The Ministry is implementing a national programme on energy recovery from urban and industrial waste, to promote new technologies such as bio-methanation, pyrolysis/gasification and combustion/incineration for the processing and disposal of waste.

Unmindful of these mandatory requirements and oblivious of the composition of Indian waste, which has a low calorific value and is hence unsuitable for electricity-generation, MNRE had for quite a long time experimented with incineration technologies despite consistent failures against the cardinal principles of waste management at considerable public cost.

The 15 May, 2007 order "permit (s) Ministry of Non-conventional Energy Sources (MNES) to go ahead for the time being with 5 pilot projects chosen by them" but it is noteworthy that this refers specifically to bio-methanation technology.

I am confident that in the light of the recent Supreme Court order, MNRE will withdraw or modify its letter (No.10/3/2005-UICA) dated 25.07.2005 & subsequent relevant letters written to Chief Secretaries of State Governments Administrators of Union Territories Heads of State Nodal Agencies Municipal Corporations/ Urban Local Bodies on the subject of "Accelerated Programme on Energy Recovery from Urban Wastes- Sanction for the Year 2005-06" with copies to Ministry of Urban Affairs & Poverty Alleviation, Ministry of Environment & Forests, Development of Science & Technology Secretary, Planning Commission, IREDA and other Financial Institutions/Banks R&D Institutions, Consultants/Consultancy Organisations and Business/Industry Associations.

I am hopeful that after the careful perusal of order and my previous letters, MNRE would make source segregation of municipal waste mandatory and put waste management practices on the right track by refraining from polluting technologies like incinerators.

Sir,>> This is with reference to Waste to Energy (WTE) Incinerators in Delhi and the emerging compelling logic to remove incinerator technologies from your Ministry’s WTE Policy.>> In a letter dated 1st April, 2011, Shri Jairam Ramesh, Union Minister of Environment & Forests wrote to Delhi’s Chief Minister notes that “there has been a violation of a basic condition stipulated in the environmental clearance” in the matter of WTE plant in Delhi. In view of the same it is incumbent on your Ministry to rescind the order according financial assistance to such projects.>> In a letter titled 'Administrative Approval' dated 26rd April, 2010, it is written that "The scheme provides financial assistance for setting up of five Pilot projects for power generation from MSW to be undertaken in accordance with the decision of Hon’ble Supreme Court given during a hearing held on May 15, 2007". I submit that this statement is factually incorrect. I have been pointing out this error since June 2007 (Refer to my letter to Secretary MNRE and Union Minister, MNRE).>> I had made submissions to the Expert Committee which were annexed to its report. We had submitted that incinerator technology (like incineration of Refuse Derived Fuel) emits Dioxins. According to World Health Organisation (WHO):>> • Dioxins are a group of chemically-related compounds that are persistent environmental pollutants.>> • Dioxins are found throughout the world in the environment and they accumulate in the food chain, mainly in the fatty tissue of animals.>> • More than 90% of human exposure is through food, mainly meat and dairy products, fish and shellfish. Many national authorities have programmes in place to monitor the food supply.>> • Dioxins are highly toxic and can cause reproductive and developmental problems, damage the immune system, interfere with hormones and also cause cancer.>> • Due to the omnipresence of dioxins, all people have background exposure, which is not expected to affect human health. However, due to the highly toxic potential of this class of compounds, efforts need to be undertaken to reduce current background exposure.>> • Prevention or reduction of human exposure is best done via source-directed measures, i.e. strict control of industrial processes to reduce formation of dioxins as much as possible.>> In view of such concerns incinerator technology is being discouraged world over. For instance, European Parliament has passed a resolution against it and UN's Stockholm Convention on Persistent Organic Pollutants seeks elimination of such technologies. Incinerators are one of the biggest sources of Dioxins. Waste Incineration is also listed as a source of green house gas emission as per Annexure A of UN's Kyoto Protocol. India is a party to these UN treaties.>> In order to keep the residents of Okhla and other areas in dark a fake public hearing was held on 20.01.2007 at Saket (quite far from the plant site) wherein the proceedings prepared by Delhi Pollution Control Committee (DPCC) itself reads: “It is pertinent to mention that no Public/public representative/ any interested person/ NGO attended the meeting for comments/objections on the Project”. The attendance sheet of Panel Members for the Public Hearing reveals that only two officials one Environmental Engineer from DPCC and another Deputy Commissioner & DM, Government of NCTD attended it. MNRE’s subsidy to such a dubious project is completely irrational.>> In such a backdrop, the May 15, 2007 order of Hon'ble Supreme Court (complete text) reads:"The matter relates to solid waste management by various Municipal Corporations. After hearing parties, this Court on 6th May, 2005, observed that till the position becomes clear as regards the viability of the projects for generation of energy from municipal waste (by the bio-methanation technology), the Government would not sanction any further subsidies to such projects. This Court also directed that the Central Government to constitute a Committee of Experts and include therein Non-Governmental Organisations as well, to inspect the functioning of the project at Lucknow and its record and file a report before this Court. Pursuant to the said order, a detailed report has been submitted by the Expert Committee on 2.1.2006. Chapter IX of the Report contains its recommendations and conclusions. The Committee is of the opinion that the choice of technology for treatment of MSW should be made on the basis of quantity and quality of waste and local conditions. The Committee has opined that operational problems of one plant (Lucknow) should not form the basis to judge the efficacy of the particular technology and therefore, petitioner's objection to providing support (subsidy) to waste to energy projects may not be justified.">> The Hon'ble Supreme Court's order reproduced parts of the Expert Committee's report saying, 'We extract below some of the relevant conclusions of the Committee:>> “ ...For all the projects in future, the issues such as Project Development>> including characterization of wastes, sizing of projects, technology selection and project design, management model and operational issues including close co-ordination between Municipal Corporation and the promoters, financial appraisal and approval of project should be adequately addressed.”>> “ In view of the problems of treatment and disposal of municipal wastes (solid and liquid) in our cities and towns, which are only likely to increase with the growth of population and urbanization, an integrated approach to waste processing and treatment will be necessary, as brought out in the MSW Rules, 2000. Therefore, instead of focusing on individual technologies, it would be desirable to take an integrated approach to the management and treatment of MSW, which would necessitate deployment of more than on technology in tandem.”>> “ The selection of technology for the solid waste management depends>> upon the quality of waste to be treated and the local conditions. Therefore, for the segregated waste, which is dedicated in nature, the selection of technology is relatively easier and its performance and success is beyond doubt. Therefore, it is desirable to have solid waste segregated at source, which is also required as per the MSW Rules, 2000.”>> The Court order is quite categorical in saying, "The Committee has recommended that projects based on bio-methanation of MSW should be taken up only on segregated/uniform waste unless it is demonstrated that in Indian conditions, the waste segregation plant/process can separate waste suitable for bio-methanation. It has opined that there is a need to take up pilot projects that promote integrated systems for segregation/collection/ transportation and processing and treatment of waste. In view of the report of the Committee and having regard to the relevant facts, we modify the order passed by this Court earlier and permit Ministry of Non-conventional Energy Sources (MNES) to go ahead for the time being with 5 pilot projects chosen by them, keeping in view the recommendations made by the Expert Committee and then take appropriate decision in the matter." Despite this MNRE erred in issuing approvals which were/are contrary to the Hon'ble Court's order.>> In view of the above the administrative approvals (available at http://mnre.gov.in/adm-approvals/energymsw-1011.pdf & http://www.mnre.gov.in/adm-approvals/aa-energy-uwaste.pdf) are in manifest violation of the Hon'ble Supreme Court's order. I have referred to it my previous letters to MNRE.>> In such a context, I wish to draw your attention towards the controversial proposal for setting up of Integrated Waste Processing Complex at Okhla (which find mention in MNRE’s letter No. 10/5/05-UICA (Part-II dated 12.2.2005 signed by A K Dhussa, Scientist “F”)). The letter erroneously refers to the site of this complex as “Okhla Landfill” for processing about 600 tpd of MSW through RDF route, biomethanation of about 100 tpd of segregated green waste and a power plant of total capacity of 6 MW. It is noteworthy that the project proponent M/s. Infrastructure Leasing and Financial Services Ltd (IL&FS) “incorporated a company named Unique Waste Processing Company (P) Ltd (UWPCPL) as 100 % subsidiary for developing Municipal Waste projects. The letter reveals that UWMCPL in turn established a company namely “Okhla Waste Management Company (P) Ltd” (OWMCPL) for implementation of this project. This company will be run by a Project Developer to be selected on the basis of competitive bidding…IL&FS and APTDC (Andhra Pradesh Technology Development and Promotion Centre) through UWPCPL will retain 26 % of the stake in OWMCPL” The letter had noted that Department of Economic Affairs (DEA), Ministry of Finance “may once again be informed about the outcome of the hearing in the Supreme Court on a PIL wherein it was decided that no further subsidy be granted for MSW projects pending further orders”.>> In another letter (10/5/05-UICA (Part-II) dated 09.01.2006 signed by A K Dhussa), it is reiterated that, “DEA may once again be informed about the outcome of the hearing in the Supreme Court on a PIL wherein it was decided that no further subsidy be granted for MSW projects pending further orders.”>> It is noteworthy that there is a letter dated 29.05.2008 (with no letter No.) signed by A K Dhussa even after the Hon’ble Supreme Court’s order of May 15, 2007 that only permits Biomethanation technology and that too only for 5 pilot projects. It has been revealed through RTI application that Delhi’s Waste to Energy project based on Incineration of RDF is not one of them. Thus, the Hon’ble Court’s order has been violated on two counts.>> Although environmental clearance dated 21st March, 2007 and amended environmental clearance dated 9th May 2007 was granted to M/s Timarpur-Okhla Waste Management Company Private Limited, the MNRE letter dated 29.05.2008 says that, “Case was made for ‘in principle’ approval at this stage since the Project Company formed by M/s IL&FS is being taken over by M/s Jindal Urban Infrastructure Ltd., (JUIL), a company”. The letter further reveals that “It was presumed that the new owners of the company will develop a fresh DeTAILED Project Report (DPR) and approach this Ministry alongwith appraisal note from lending bank/financial institution. M/s JUIL have, however, sent only a Project Appraisal Memo (PAM) and have requested for sanction of financial assistance for this project.” There is reference 20 MW and 16 MW after the initial reference to 6 MW in the MNRE letter dated 12.2.2005.>> In a reply dated December 11, 2009 in the Lok Sabha in the backdrop of foundation stone laid on June 26, 2010 by Mrs Sheila Dikshit, Delhi’s Chief Minister for a polluting waste to energy plant in the residential area, the MNRE stated, “Our Ministry is implementing a programme for setting up five pilot projects on Energy recovery from municipal solid waste”. Initially, Delhi Government claimed in the Delhi High Court that it was one of the five projects MNRE referred to in its reply, which the court later found to be not true.>> MNRE and Delhi government and have been misled into promoting this dubious technology despite incontrovertible evidence against the technology and in spite of its explicit exclusion by the Prime Minister’s National Action Plan for Climate Change. While no one will allow a incinerator based plant in one's own backyard or in one's own residential area, the same is being done by the Delhi Government and your Ministry. In an open letter to the Chief Minister which is attached for your perusal, the residents said, “This plant will emit large quantities of hazardous and toxic emissions (such as dioxins and furans) due to burning of Municipal Solid Waste, and will profoundly affect the health of the people living in the surrounding areas and environment for all times to come in future.”>> Union Ministry of New and Renewable Energy (MNRE) must take cognizance of the sad plight at waste to energy site in Gandhamguda village in Ranga Reddy district of Andhra Pradesh (wrongly mentioned as Hyderabad project) which had the same technology. While the RDF incinerator was in operation, the village was covered by a heavy shroud of dark smoke. Originally a pelletisation plant with a furnace, After the plant came up, local doctors started detecting case of problems not found before — skin rashes, asthma, respiratory problems and some cases of stillborns. In a statement, Gandhamguda sarpanch D. Shakuntala had said: ‘‘Everyone in Peerancheru Gram Panchayat and its adjoining regions is now contaminated with harmful pollutants and symptoms are visible in the form of brain fever, vomiting, jaundice, asthma, miscariages, infertility.’’ Similar fate awaits residents of Delhi.>> For misplaced carbon revenue, it would not be appropriate to turn Delhi residents as guinea pigs. MNRE has an incorrect policy of subsidizing hazardous technologies like proposed incinerators.>> Environmental groups, recycling workers and neighborhood residents are demanding closure of this combustion based project for a just transition from burning waste to building a better, cleaner future for the residents of Delhi. The transition is necessary in the face of issues such as the high cost of incineration, health effects of pollution in neighborhoods, and adverse climate change. Children suffer asthma rates three times the national average among other devastating health impacts.>> This plant is based on a hazardous technology that receives fiscal incentives from Union Ministry of New and Renewable Energy (MNRE). Notably, while 'whether or not energy from mixed municipal waste (with hazardous characteristics) is a driving concern' remains in dispute, the Prime Minister’s National Action Plan on Climate Change (NAPCC) categorically refers to Biomethanation technology, a biological treatment method for waste to energy instead of the Refuse Derived Fuel (RDF) process which is a incineration technology and is a tried, tested, failed and Dioxins emitting technology.>> MNRE and Delhi Chief Minister turned a blind eye to Delhi High Court order which led to an inquiry by the Comptroller and Auditor General of India (CAG) into the failure of the Timarpur plant that was also based on incineration technology (namely Refuse Derived Fuel) and the ‘White Paper on Pollution in Delhi with an Action Plan’ prepared by Union Ministry of Environment and Forests, the Chief Minister has been misled into promoting it. The White Paper says, “The experience of the incineration plant at Timarpur, Delhi and the briquette plant at Bombay support the fact that thermal treatment of municipal solid waste is not feasible, in situations where the waste has a low calorific value. A critical analysis of biological treatment as an option was undertaken for processing of municipal solid waste in Delhi and it has been recommended that composting will be a viable option. Considering the large quantities of waste requiring to be processed, a mechanical composting plant will be needed.”>> Even Municipal Corporation of Delhi’s own Feasibility Study and Master Plan for Optimal Waste Treatment and Disposal for the Entire State of Delhi of March 2004 says, “Incineration of RDF is considered waste incineration.” (Page 25, Appendix D, Technology Catalogue). It also says the costs of RDF are often high for societies with low calorific value because energy is used to dry the waste before it becomes feasible to burn it.>> In fact the Master Plan Report (2020) of Municipal Corporation of Delhi (MCD) itself says,... “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” One is surprised that despite this observation the report then goes on to suggest RDF. In fact the MCD report itself says that RDF is another form of incineration.>> A 10 member Fact Finding Team visited the plant site on 18th June 2010 to take stock of the situation. Its preliminary findings are as follows: 1. RDF or incineration is completely inappropriate for Indian urban waste, which is largely biodegradable in nature. They extract a very high cost for the energy which they claim to generate. 2. The cost largely subsidised by various schemes, does not however include the environmental and health costs caused by their toxic releases, and which are externalized. 3. These technologies also use valuable resources which can be recycled, such as plastics and metals, and which support a massive recycling sector in the country. Indian municipal waste is fit for composting and bio-methanation treatment processes. 4. RDF is a thermal and combustion technology, mainly used to prepare waste for mass incineration. 5. If mixed waste is burnt will create problems of very toxic compounds such as dioxins and furans, heavy metals and other pollutants. 6. The calorific value for the waste comes from materials such as plastics and metals. 7. Plastics, especially chlorinated plastics such as polyvinyl chloride (PVC) when combusted gives rise to these highly toxic pollutants and 8. PVC plastic combustion which is part of the mixed waste is banned in India by regulation both in the municipal and bio-medical waste handling rules.>> As per an agreement, BSES Rajdhani Power Limited (BRPL) will procure 50 per cent of the 16 MW electricity to be produced by TOWMCL at its plant in Okhla in the vicinity of numerous residential areas such as Sukhdev Vihar, Hazi Colony, Gaffar Manzil and others. The plant being set up plans to process over 6, 43, 500 lakh metric tonnes or one third of Delhi's Municipal Solid Waste (MSW) per year generated in Delhi. The plant is scheduled to be commissioned in late 2010-2011. Around 1,300 Tonnes Per Day (TPD) of MSW will be sourced from the Okhla landfill site and 650 TPD from Timarpur. BRPL will procure power at a DERC approved competitive tariff rate, determined by a competitive bidding process. The agreement allows the promoters to sell the remaining 50 per cent electricity through a suitable open access mechanism.>> Similar waste to energy project is coming up at Ghazipur and Bawna-Narela as well. Earlier, in November, 2009 BRPL had signed a 25-year-agreement to procure 49 per cent of the electricity generated from garbage to energy project at Ghazipur.>> Unmindful of the environmental and human cost the installation of proposed municipal solid waste (MSW) to energy plants in Ghazipur, Timarpur and Okhla, based on incineration of Refuse Derived Fuel (RDF) is being pursued. This compelled the residents to move to the Delhi High Court. Earlier, the matter came up for hearing on December 11, 2009 wherein the petitioners (Sukhdev Vihar Residents Welfare Association & others) pointed out the polluting nature of the Refuse Derived Fuel (RDF) Incineration technology and how both the central government and the Delhi government has misled the court. The court in its latest order has found that it was misled earlier which had led to it dismissing the petition which has now been restored and is scheduled for hearing on 22nd July before the Delhi High Court. In the presence of A.S. Chandihok, Additional Solicitor General, the bench headed by the Chief Justice, Delhi High Court in an order dated 15th January observed, “that the project in question” and “the location of the pilot project in Delhi was neither recommended by the Expert Committee nor approved by the Supreme Court.”>> East Delhi Waste Processing Company Private Limited, a special purpose vehicle of the latter company is working for generating electricity at the Ghazipur site with the support of the Delhi Government. ‘New Delhi Waste Processing Company Private Limited’ a Joint Venture company of Delhi Government, IL&FS and APTTDC is supporting the project as well. The integrated municipal waste-processing complex is proposed to include a MSW processing plant at Ghazipur to produce Refuse Derived Fuel (RDF) along with a power plant of 10 MW capacity where the RDF derived from the waste will be used as fuel to produce electricity. It is supposed to handle an average 1300 tons per day. It claims that 111,949 metric tonnes CO2 equivalent per annum of green house gases would be reduced. The crediting period for the project is from 1st November, 2010 to 31 October, 2020.>> The Timarpur-Okhla carbon credit project which was registered on 10th November, 2007 with a claim to reduce green house gases to the tune of 262,791 metric tonnes CO2 equivalent per annum. Unique Waste Processing Company, a subsidiary of Infrastructure Leasing and Financial Services (IL&FS) and Andhra Pradesh Technology Development Centre (APTDC) has incorporated Timarpur-Okhla Waste Management Company for developing the project for processing municipal waste and also to produce electricity at two locations namely Timarpur and Okhla, at the site at Okhla that is adjacent to defunct Okhla Sewage Treatment Plant (STP). TOWMCL is working with New Delhi Municipal Council (NDMC) and MCD. The Timarpur and Okhla plant will together be processing 650 tonnes per day of MSW at Timarpur site and 1300 tonnes per day of MSW at Okhla and claims to generate 16 MW of electricity.>> The move underway to install RDF plants in Delhi and several other state capitals is an environmentally unsustainable solution, which should be deemed unacceptable. If Delhi allows such toxic plant, it will set a bad precedent for other cities. It raises serious concerns about the health and safety of the citizens, which such a technology, will jeopardize.>> In view of these grave concerns which Delhi residents, environmental groups and waste recyclers face, it is rational to demand stoppage of WTE projects in Delhi and removing incinerator from the WTE policy at the earliest.>> Yours Sincerely>> Gopal Krishna, Convener>> ToxicsWatch Alliance, New Delhi, Mb: 9818089660>> Website: www.toxicswatch.com>> Blog: toxicswatch.blogspot.com>> Cc Dr Manmohan Singh, Prime Minister, Government of India> Shri Jairam Ramesh, Union Minister of Environment & Forests> Shri Tajendar Khanna, Lt Governor, Delhi> Smt Sheila Dikshit, Chief Minister of Delhi> Prof. S. P Gautam, Chairman, Central Pollution Control Board> Mr Bharat Bhushan, Director, Union Ministry of Environment & Forests>>>> On Tue, Jul 20, 2010 at 2:51 PM, Gopal Krishna wrote:>>>> To>>>> Dr. Farooq Abdullah,>> Union Cabinet Minister>> Ministry of New and Renewable Energy>> Government of India>> Block-14, CGO Complex,>> Lodhi Road,New Delhi-110003>>>> Subject-Seeking Appointment to Discuss Waste to Energy Plants in>> Residential Areas of Delhi>>>> Sir,>>>> This is to seek an appointment to meet you with a small delegation>> from Delhi based Residential Welfare Associations, environmental>> groups and waste recyclers in the matter of proposed waste to energy>> plants based on incineration technology in general and Timarpur-Okhla>> Waste to Energy project in particular.>>>> I wish to draw your attention towards the Timarpur-Okhla Waste to>> Energy project that has met with protest rally from the residents of>> Gaffar Manzil, Sukhdev Vihar and Hazi Colony together. Local>> politicians have also pledged their support for the protesters. Over>> 600 people walked through the colonies in a procession to stage their>> protest. The proposed plant is located inside dozens of densely>> populated residential colonies like Harkesh Nagar and Johori Farm,>> when the policy of the government is to shift or relocate all existing>> industries whatsoever from the residential areas. Besides this the>> site is in proximity of hospitals like Holy Family, Fortis-Escorts and>> Apollo. Inhabitants of colonies like Gaffar Manzil, Sukhdev Vihar and>> Hazi Colony are rightly alarmed at the prospect of a Dioxins emitting>> incinerator plant from coming up in their vicinity.>>>> This has reference to your reply dated December 11, 2009 in the Lok>> Sabha and laying of foundation stone on June 26, 2010 by Mrs Sheila>> Dikshit, Delhi’s Chief Minister for a polluting waste to energy plant>> in the residential area despite the experience of Bhopal Gas Leak>> Disaster.>>>> In your reply it was stated, “Our Ministry is implementing a programme>> for setting up five pilot projects on Energy recovery from municipal>> solid waste”. Initially, Delhi Government claimed in the Delhi High>> Court that it was one of the five projects you referred to in your>> reply, which the court later found to be not true.>>>> Your Ministry and Delhi government and have been misled into promoting>> this dubious technology despite incontrovertible evidence against the>> technology and in spite of its explicit exclusion by the Prime>> Minister’s National Action Plan for Climate Change.>>>> While no one will allow a incinerator based plant in one's own>> backyard or in one's own residential area, the same is being done by>> the Delhi Government and your Ministry. In an open letter to the>> Chief Minister which is attached for your perusal, the residents said,>> “This plant will emit large quantities of hazardous and toxic>> emissions (such as dioxins and furans) due to burning of Municipal>> Solid Waste, and will profoundly affect the health of the people>> living in the surrounding areas and environment for all times to come>> in future.”>>>> Union Ministry of New and Renewable Energy (MNRE) must take cognizance>> of the sad plight at waste to energy site in Gandhamguda village in>> Ranga Reddy district of Andhra Pradesh (wrongly mentioned as Hyderabad>> project) which had the same technology. While the RDF incinerator was>> in operation, the village was covered by a heavy shroud of dark smoke.>> Originally a pelletisation plant with a furnace, After the plant came>> up, local doctors started detecting case of problems not found before>> — skin rashes, asthma, respiratory problems and some cases of>> stillborns. In a statement, Gandhamguda sarpanch D. Shakuntala had>> said: ‘‘Everyone in Peerancheru Gram Panchayat and its adjoining>> regions is now contaminated with harmful pollutants and symptoms are>> visible in the form of brain fever, vomiting, jaundice, asthma,>> miscariages, infertility.’’ Similar fate awaits residents of Delhi.>> For misplaced carbon revenue, it would not be appropriate to turn>> Delhi residents as guinea pigs. MNRE has an incorrect policy of>> subsidizing hazardous technologies like proposed incinerators.>>>> Environmental groups, recycling workers and neighborhood residents are>> demanding closure of this combustion based project for a just>> transition from burning waste to building a better, cleaner future for>> the residents of Delhi. The transition is necessary in the face of>> issues such as the high cost of incineration, health effects of>> pollution in neighborhoods, and adverse climate change. Children>> suffer asthma rates three times the national average among other>> devastating health impacts.>>>> This plant is based on a hazardous technology that receives fiscal>> incentives from Union Ministry of New and Renewable Energy (MNRE).>> Notably, while 'whether or not energy from mixed municipal waste (with>> hazardous characteristics) is a driving concern' remains in dispute,>> the Prime Minister’s National Action Plan on Climate Change (NAPCC)>> categorically refers to Biomethanation technology, a biological>> treatment method for waste to energy instead of the Refuse Dervied>> Fuel (RDF) process which is a incineration technology and is a tried,>> tested, failed and Dioxins emitting technology.>>>> Your Ministry and Delhi Chief Minister has turned a blind eye to Delhi>> High Court order which led to an inquiry by the Comptroller and>> Auditor General of India (CAG) into the failure of the Timarpur plant>> that was also based on incineration technology (namely Refuse Derived>> Fuel) and the ‘White Paper on Pollution in Delhi with an Action Plan’>> prepared by Union Ministry of Environment and Forests, the Chief>> Minister has been misled in to promoting it. The White Paper says,>> “The experience of the incineration plant at Timarpur, Delhi and the>> briquette plant at Bombay support the fact that thermal treatment of>> municipal solid waste is not feasible, in situations where the waste>> has a low calorific value. A critical analysis of biological treatment>> as an option was undertaken for processing of municipal solid waste in>> Delhi and it has been recommended that composting will be a viable>> option. Considering the large quantities of waste requiring to be>> processed, a mechanical composting plant will be needed.”>>>> Even Municipal Corporation of Delhi’s own Feasibility Study and Master>> Plan for Optimal Waste Treatment and Disposal for the Entire State of>> Delhi of March 2004 says, “Incineration of RDF is considered waste>> incineration.” (Page 25, Appendix D, Technology Catalogue). It also>> says the costs of RDF are often high for societies with low calorific>> value because energy is used to dry the waste before it becomes>> feasible to burn it.>>>> In fact the Master Plan Report (2020) of Municipal Corporation of>> Delhi (MCD) itself says,... “RDF is often an option when emission>> standards are lax and RDF is burned in conventional boilers with no>> special precautions for emissions.” One is surprised that despite this>> observation the report then goes on to suggest RDF. In fact the MCD>> report itself says that RDF is another form of incineration.>>>> A 10 member Fact Finding Team visited the plant site on 18th June 2010>> to take stock of the situation. Its preliminary findings are as>> follows: 1. RDF or incineration is completely inappropriate for Indian>> urban waste, which is largely biodegradable in nature. They extract a>> very high cost for the energy which they claim to generate. 2. The>> cost largely subsidised by various schemes, does not however include>> the environmental and health costs caused by their toxic releases, and>> which are externalized. 3. These technologies also use valuable>> resources which can be recycled, such as plastics and metals, and>> which support a massive recycling sector in the country. Indian>> municipal waste is fit for composting and bio-methanation treatment>> processes. 4. RDF is a thermal and combustion technology, mainly used>> to prepare waste for mass incineration. 5. If mixed waste is burnt>> will create problems of very toxic compounds such as dioxins and>> furans, heavy metals and other pollutants. 6. The calorific value for>> the waste comes from materials such as plastics and metals. 7.>> Plastics, especially chlorinated plastics such as polyvinyl chloride>> (PVC) when combusted gives rise to these highly toxic pollutants and>> 8. PVC plastic combustion which is part of the mixed waste is banned>> in India by regulation both in the municipal and bio-medical waste>> handling rules.>>>> Earlier residents had not allowed the land hand over ceremony for the>> project that is proposed in the residential area of Okhla but>> unmindful of the public protest, New Delhi Municipal Corporation>> (NDMC) had permitted Jindal Urban Infrastructure Ltd to set up this>> plant. This company has secured a contract from New Delhi Waste>> Processing Company Limited, a joint venture between the Delhi>> Government and Infrastructure Leasing and Financial Services Ltd.>> (IL&FS), to produce 16 MW power from 2, 000 metric tonnes of municipal>> waste. Jindal company’s misplaced claims to that effect that it will>> process nearly 2000 tonnes of waste, later it would be in a position>> to process as much as 4,000 tonnes based on obsolete technology will>> distort capital city’s waste management beyond repair.>>>> The proposed polluting technology to deal with the waste from South>> Delhi, North West Delhi and East Delhi is fraught with disastrous>> public health consequences for which two companies namely,>> Timarpur-Okhla Waste Management Company (TOWMCL) and the Unique Waste>> Processing Company (subsidiary of IL&FS Infrastructure Development>> Corporation Limited have been set up.>>>> As per the agreement, BRPL will procure 50 per cent of the 16 MW>> electricity to be produced by TOWMCL at its plant in Okhla in the>> vicinity of numerous residential areas such as Sukhdev Vihar, Hazi>> Colony, Gaffar Manzil and others. The plant being set up plans to>> process over 6,43,500 lakh metric tonnes or one third of Delhi's>> Municipal Solid Waste (MSW) per year generated in Delhi. The plant is>> scheduled to be commissioned in late 2010-2011. Around 1,300 Tonnes>> Per Day (TPD) of MSW will be sourced from the Okhla landfill site and>> 650 TPD from Timarpur. BRPL will procure power at a DERC approved>> competitive tariff rate, determined by a competitive bidding process.>> The agreement allows the promoters to sell the remaining 50 per cent>> electricity through a suitable open access mechanism.>>>> Similar waste to energy project is coming up at Ghazipur as well.>> Earlier, in November, 2009 BRPL had signed a 25-year-agreement to>> procure 49 per cent of the electricity generated from garbage to>> energy project at Ghazipur. Chief Minister referred to this project as>> well while laying the foundation stone.>>>> Unmindful of the environmental and human cost the installation of>> proposed municipal solid waste (MSW) to energy plants in Ghazipur,>> Timarpur and Okhla, based on incineration of Refuse Derived Fuel (RDF)>> is being pursued. This compelled the residents to move to the Delhi>> High Court. Earlier, the matter came up for hearing on December 11,>> 2009 wherein the petitioners (Sukhdev Vihar Residents Welfare>> Association & others) pointed out the polluting nature of the Refuse>> Derived Fuel (RDF) Incineration technology and how both the central>> government and the Delhi government has misled the court. The court in>> its latest order has found that it was misled earlier which had led to>> it dismissing the petition which has now been restored and is>> scheduled for hearing on 22nd July before the Delhi High Court. In the>> presence of A.S. Chandihok, Additional Solicitor General, the bench>> headed by the Chief Justice, Delhi High Court in an order dated 15th>> January observed, “that the project in question” and “the location of>> the pilot project in Delhi was neither recommended by the Expert>> Committee nor approved by the Supreme Court.”>>>> East Delhi Waste Processing Company Private Limited, a special purpose>> vehicle of the latter company is working for generating electricity at>> the Ghazipur site with the support of the Delhi Government. ‘New Delhi>> Waste Processing Company Private Limited’ a Joint Venture company of>> Delhi Government, IL&FS and APTTDC is supporting the project as well.>> The integrated municipal waste-processing complex is proposed to>> include a MSW processing plant at Ghazipur to produce Refuse Derived>> Fuel (RDF) along with a power plant of 10 MW capacity where the RDF>> derived from the waste will be used as fuel to produce electricity. It>> is supposed to handle an average 1300 tons per day. It claims that>> 111,949 metric tonnes CO2 equivalent per annum of green house gases>> would be reduced. The crediting period for the project is from 1st>> November, 2010 to 31 October, 2020.>>>> The Timarpur-Okhla carbon credit project which was registered on 10th>> November, 2007 with a claim to reduce green house gases to the tune of>> 262,791 metric tonnes CO2 equivalent per annum. Unique Waste>> Processing Company, a subsidiary of Infrastructure Leasing and>> Financial Services (IL&FS) and Andhra Pradesh Technology Development>> Centre (APTDC) has incorporated Timarpur-Okhla Waste Management>> Company for developing the project for processing municipal waste and>> also to produce electricity at two locations namely Timarpur and>> Okhla, at the site at Okhla that is adjacent to defunct Okhla Sewage>> Treatment Plant (STP). TOWMCL is working with New Delhi Municipal>> Council (NDMC) and MCD. The Timarpur and Okhla plant will together be>> processing 650 tonnes per day of MSW at Timarpur site and 1300 tonnes>> per day of MSW at Okhla and claims to generate 16 MW of electricity.>>>> The move underway to install RDF plants in Delhi and several other>> state capitals is an environmentally unsustainable solution, which>> should be deemed unacceptable. If Delhi allows such toxic plant, it>> will set a bad precedent for other cities. It raises serious concerns>> about the health and safety of the citizens, which such a technology,>> will jeopardize.>>>> In view of these grave concerns which Delhi residents, environmental>> groups and waste recyclers face, please grant us an appointment to>> meet you as a delegation and apprise of the situation at the earliest.>>>> warm regards>> Gopal Krishna>> Founder-Convener>> ToxicsWatch Alliance>> New Delhi>> Mb: 9818089660>> Website: www.toxicswatch.com>> Blog: toxicswatch.blogspot.com>>> ---------- Forwarded message ---------->> From: Gopal Krishna >> Date: Wed, Jun 6, 2007 at 6:43 PM>> Subject: Supreme Court order on Biomethanation Technology>> To: secymnes@nic.in>> To>> Shri V. Subramanian>> Secretary>> Ministry of New and Renewable Energy (MNRE),>> Block-14, CGO Complex,>> Lodhi Road, New Delhi-110 003>> Subject-Supreme Court order of 15 May, 2007 on Biomethanation Technology based municipal waste to energy projects>> Sir,>> With due respect I wish to draw your attention towards a case which came up for hearing in the Supreme Court on 15/5/2007. The case dealt with your ministry's role in municipal waste to energy projects and its failures. The Ministry is implementing a national programme on energy recovery from urban and industrial waste, to promote new technologies such as bio-methanation, pyrolysis/gasification and combustion for the processing and disposal of waste.>> In the context of widespread concern about global warming, the order is quite significant since it does not allow waste incineration. As per Annexure A of the Kyoto Protocol, waste incineration is a green house gas emitter. Besides it is a well known emitter of Persistent Organic Pollutants (POPs) and heavy metals as per Stockholm Convention and UNEP's Mercury Assessment Report. India is a signatory to these international treaties.>> Upon hearing the application of the Union Ministry of New and Renewable Energy, the court has passed its order wherein it has referred to the findings of the Committee of Experts on Waste to Energy saying, "it is desirable to have solid waste segregated at source, which is also required as per the MSW Rules, 2000.">> Unmindful of these mandatory requirements and oblivious of the composition of Indian waste, which has a low calorific value and is hence unsuitable for electricity-generation, MNRE had for quite a long time experimented with incineration technologies despite consistent failures against the cardinal principles of waste management at considerable public cost.>> The 15 May, 2007 order "permit (s) Ministry of Non-conventional Energy Sources (MNES) to go ahead for the time being with 5 pilot projects chosen by them" but it is noteworthy that this refers specifically to bio-methanation technology.>> I am confident that in the light of the most recent Supreme Court order, MNRE will withdraw or modify its letter (No.10/3/2005-UICA) dated 25.07.2005 written to Chief Secretaries of State Governments Administrators of Union Territories Heads of State Nodal Agencies Municipal Corporations/ Urban Local Bodies on the subject of "Accelerated Programme on Energy Recovery from Urban Wastes- Sanction for the Year 2005-06" with copies to Ministry of Urban Affairs & Poverty Alleviation, Ministry of Environment & Forests, Development of Science & Technology Secretary, Planning Commission, IREDA and other Financial Institutions/Banks R&D Institutions, Consultants/Consultancy Organisations and Business/Industry Associations.>> Although it is not a significant omission, I am surprised to note that the Ministry did not deem it fit to inform the court of its new name- Ministry of New and Renewable Energy. The 15th May, 2007 order refers to it as Ministry of Non-conventional Energy Sources (MNES).>> I am hopeful that after the careful perusal of order MNRE would make source segregation of municipal waste mandatory and put waste management practices on the right track by refraining from polluting technologies like incinerators.>> Thanking you in anticipation>> Yours Sincerely>> Gopal Krishna>> ToxicsWatch Alliance>> Mb: 9818089660>> New Delhi>> Web: toxicswatch.blogspot.com